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2018 (5) TMI 1325 - AT - Income TaxReopening of assessment - existence of reasons to believe - Held that:- We have to necessarily hold that the reopening is bad in law, as in this case on hand, there is no whisper, much less an allegation that there is failure on the part of the assessee to disclose fully and truly all material facts, necessary for assessment. Hence the mandatory requirements of the proviso to section 147 has not been fulfilled in this case. We hold that the reopening is bad in law as the reasons recorded are without independent application of mind. - Decided in favour of assessee
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